AWO Letter - The American Waterways Operators

Phone: (703) 841-9300
Fax: (703) 841-0389
ISSN1536-3910
www.americanwaterways.com
801 North Quincy Street, Suite 200, Arlington, Virginia 22203
GAO Recommends More Focus on
Domestic Maritime Training Needs
On January 31, the U.S. Government
Accountability Office released a report on
the training needs of the U.S. maritime
workforce. The report, mandated by the
Coast Guard and Maritime Transportation
Act of 2012, examines:
•
The availability of maritime training;
•
The U.S. Maritime Administration’s
actions to ensure that mariners meet
commerce and defense needs, as well
as industry stakeholder views on
MARAD’s actions.
•
The availability of financial
assistance for maritime training; and,
AWO provided input to the GAO
research team that conducted the study.
The report cites officials from three
maritime academies that expressed the
need for more information to develop
courses to meet the training requirements
of the domestic maritime industry. The
report also cites several industry stakeVOLUME 71, NO. 3 • FEBRUARY 11, 2014
HIGHLIGHTS IN THIS ISSUE
AWO ASP and IVSP Sent to
Coast Guard for Reapproval.................2
EPA Announces Upcoming
VGP Webinar on EALs..........................2
EPA Revises List of Certified Marine
Engine Remanufacture Kits..................3
AWO Promotes Industry Efforts
to Reduce Air Emissions.......................4
Atlantic Region Annual Meeting
Takes Place in Baltimore.......................5
AWO Submits Comments Urging
Chicago to Change Petcoke Rule.........6
holders that expressed similar concerns
about the lack of academy
curricula tailored specifically
for the domestic maritime
sector. U.S. Merchant
Marine Academy
officials, however, did
note that they offer some
elective courses in towing.
The report concluded that
MARAD should increase its focus
on supporting the domestic maritime
industry by collecting and analyzing
industry data to determine potential
problems. The GAO also
recommended that MARAD study
and identify potential problems in
ensuring that U.S. mariners are
adequately trained to meet the
needs of the entire maritime
industry. For more information on
the report, please contact Brian
Bennett at (703) 841-9300, extension
279, or [email protected].
Coast Guard Confirms Plans for
STCW Public Meeting
The Coast Guard will host a public
meeting to discuss the STCW final rule
on February 11 from 1:00 to 3:00 p.m.
Eastern time. The meeting will
take place in the Oklahoma
Room at the Department of
Transportation Conference
Center at 1200 New Jersey
Ave. SE in Washington,
DC, and will also be
available for participation by
teleconference at (888) 7902035, passcode 2251051.
The Coast Guard will present the major
areas of change in domestic regulations
and discuss implementation of these
changes. While STCW does not impact
mariners working on domestic inland
routes, the final rule does make certain
changes to domestic credentials to
harmonize them with STCW
requirements and create pathways for
mariners to receive their STCW
endorsements. The Coast Guard will host
a limited question and answer session
after the presentations. Participants at the
meeting and on the conference
bridge can ask questions during
this session or may submit
questions via email to
[email protected]. The
presentations will be made
available on the National
Maritime Center website at
http://www.uscg.mil/nmc/videos/.
For more information, click here. If you
plan to attend the meeting in person,
please RSVP by contacting Mr. E.J.
Terminella of the U.S. Coast Guard at
(202) 372-1239 or
[email protected]. For
questions about the STCW final rule,
please contact Brian Vahey at (703) 8419300, extension 251, or
[email protected].
AGENCY ACTIONS
AWO ASP and IVSP
Sent to Coast Guard
for Reapproval
On January 31, AWO submitted the
revised AWO Alternative Security
Program and International Vessel
Security Plan to the U.S. Coast Guard
for review and approval. The revisions,
which were developed and reviewed
by the AWO Security Working Group,
incorporate the new security
familiarization training requirements
for vessels subject to STCW, eliminate
references to the Coast Guard’s
discontinued Homeland Security
Advisory System and include a
number of administrative edits to
clarify member compliance
responsibilities.
AWO hopes to have the revised ASP
and IVSP approved and ready to
circulate to members by early March.
The current versions of the ASP and
IVSP remain valid until March 31 and
April 8, respectively.
For more information, please contact
Brian Vahey at (703) 841-9300,
extension 251, or
[email protected].
Corps Extends GLMRIS Report
Comment Period, Adds Two
Public Meetings
In response to a request by Sen. David Vitter
(R-LA) and comments made by AWO
members at public meetings, the U.S. Army
Corps of Engineers has extended the Great
Lakes and Mississippi River Interbasin Study
comment period through March 31.
Due to public requests, the Corps will also hold two additional public
meetings, in Portage, IN, on February 11 and in Buffalo, NY, on February
13. For more information, or to register in advance to speak at these
meetings, please click here to visit the GLMRIS Report website.
The GLMRIS Report presents eight alternatives for preventing the transfer
of aquatic invasive species, including Asian carp, between the Great Lakes
and Mississippi River basins. Four of the alternatives involve the complete
or partial hydrologic separation of the basins through the construction of
physical barriers at various points in the Chicago Area Waterways System.
These options would adversely impact thousands of marine transportationreliant jobs and businesses throughout the Great Lakes and Mississippi
River systems.
For more information, please contact Lynn Muench at (314) 446-6474 or
[email protected], or Caitlyn Stewart at (703) 841-9300,
extension 262, or [email protected].
EPA Announces Upcoming
VGP Webinar on EALs
The U.S. Environmental Protection Agency has announced it will hold a
webinar on the subject of environmentally acceptable lubricants, or EALs,
on February 14 at 10:00 a.m. Eastern for the owners and operators of
vessels covered by the 2013 Vessel General Permit. To register for the
webinar, please click here.
The 2013 VGP requires vessels covered under the permit to use EALs in all
oil-to-sea interfaces unless it is technically
infeasible to do so. The definition of EALs, the
circumstances under which EPA will consider them
technically infeasible to use, and related
recordkeeping and reporting requirements can be
found in Part 2.2.9 of the VGP.
For more information, please contact Caitlyn
Stewart at (703) 841-9300, extension 262, or
[email protected].
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February 11, 2014
AGENCY ACTIONS
EPA Revises List of Certified Marine Engine Remanufacture Kits
The U.S. Environmental Protection
Agency approved 12 remanufacture
kits for 31 engine models used on
tugboats and towboats in the
month of December 2013. To
download the list of
approved kits, please click
here.
kit is available. Kits are considered
available 120 days after their
approval by EPA. Vessel
owners with less than $5
million in annual
revenues fleet-wide are
exempt from the
provision.
although they are certified, they are not
required to be used when a compatible
engine model is remanufactured. In
addition, a kit manufactured by
OceanAir Environmental for EMD
engines was approved on November
26, 2013, and will be considered
available on March 21.
The kits were approved
under the remanufacture
provision in EPA’s Tier 3 and Tier
4 emissions regulations for Category 1
and Category 2 marine diesel engines,
promulgated in 2008. The provision
applies to engines over 800
horsepower built between 1973 and
2012, and requires owners of vessels
equipped with such engines who
replace all of the engine’s power
assemblies (either at once or over a
five-year period) to use an EPAapproved remanufacture kit, if such a
Two of the recently
certified remanufacture kits
are for Caterpillar engines and
10 are for EMD engines. With the
exception of two of the EMD kits, all
were considered available beginning
January 1. The 120-day delay did not
apply for these kits because they are for
engines for which remanufacture kits
have already been approved and were
certified by EPA based on “carryover
data” from previous manufacturer tests.
The remaining two EMD kits do not
have availability dates because,
EPA has developed an electronic
mailing list to notify the public when
an engine remanufacture kit is
approved. To sign up to receive these
notifications, and to see a complete list
of engine remanufacture kits that EPA
has certified, click here. AWO will
continue to notify members of future
kit approvals through the AWO Letter.
The Merchant Marine Personnel
Advisory Committee will meet in
Dania Beach, FL, March 11-12. The
Federal Register notice and agenda for
the meeting can be viewed here.
MERPAC working groups will meet
March 11 and present updates on their
work to the full committee on March
12. Subjects of MERPAC working
group activity include:
certification requirements; and,
requirements for mariners working on
vessels in Polar regions will help form
the basis of the U.S. position at the
February 17 meeting of the IMO
Subcommittee on Human Element,
Training and Watchkeeping that will
take up portions of the draft Polar
Code. MERPAC and AWO will be
represented at that meeting by Ira
Douglas of Crowley Maritime
Corporation.
For more information, please contact
Caitlyn Stewart at (703) 841-9300,
extension 262, or
[email protected].
Merchant Marine Personnel Advisory Committee
to Meet March 11-12 in Florida
•
•
•
•
Implementation of the Maritime
Labor Convention;
Development of competency
requirements for mariners on
vessels working in Polar regions;
Crew training requirements for
personnel on natural gas-fueled
vessels;
Utilizing military education,
training and assessment to meet
STCW and Coast Guard
February 11, 2014
•
STCW competency requirements
for chief engineers on high
horsepower, limited tonnage
vessels.
A sizable number of oceangoing
towing vessels fall into the high
horsepower, limited tonnage category,
and AWO has worked closely with
members and the Coast Guard to
ensure that chief engineers on these
vessels are not subjected to the same
regulations as their counterparts on
large deep draft vessels. The MERPAC
work on this issue will be used as the
basis of the U.S. position in upcoming
IMO proceedings where the delegation
will work to ensure that chief
engineers on towing vessels have their
own separate competency table in the
STCW regulations. Similarly, the work
of the MERPAC working group on
MERPAC is a federal advisory
committee that makes
recommendations to the Coast Guard
regarding training, credentialing and
fitness standards for U.S. merchant
mariners. For information on the
upcoming meeting please contact
Kevin Dowling at (703) 841-9300,
extension 264, or
[email protected].
3
AGENCY ACTIONS/SAFETY NEWS
AWO Promotes Industry Efforts to Reduce Air Emissions
On January 12, AWO participated in a
panel discussion titled “Reducing
Evaporative Emissions in Marine
Transportation” held at the
Transportation Research Board’s 93rd
Annual Meeting in Washington, DC.
The purpose of the panel was to
promote the efforts that the tank barge
industry and numerous state agencies
have made to reduce inadvertent
emissions from tank barges. AWO
Government Affairs Manager Brian
Vahey was joined on the panel by
representatives from the Environmental
Defense Fund, the International
Council on Clean Transportation, and
the Eastern Research Group, Inc. To
view AWO’s presentation, click here.
AWO’s presentation provided
background on the tugboat, towboat
and barge industry’s commitment to
the environment by focusing on
AWO’s best management practices to
reduce inadvertent emissions from tank
barges and its work with state agencies
to measure the effects of these
emissions on the environment. AWO
noted that since 2005, separate studies
in Louisiana, Texas and Tennessee have
demonstrated that inadvertent emissions
from tank barges do not have a
significant impact on the environment.
Despite this, the tank barge industry has
taken steps to further improve the
BMPs: three years after the guidance
document was initially developed in
2006, AWO’s Inland Liquid Sector
Committee voted to further revise the
recommended practices. This work has
been supported by state environmental
agencies, the Coast Guard and the
Chemical Transportation Advisory
Committee.
During the TRB panel, AWO cited the
positive results of recent emissions
studies as evidence that the BMPs and
TSAC to Hold Conference
Call on AIS Encoding
On February 25, the Towing Safety Advisory Committee will hold
a conference call to discuss a report from its working group on
recommendations to improve AIS encoding for towing vessels. TSAC voted
to accept this tasking in January 2013, in response to January 2012 guidance
from the Coast Guard asking operators to input four-digit destination codes
into their AIS to indicate the origin and destination of their voyage. At the
time the guidance was published, AWO expressed concern that the complex
coding structure, which includes unique identifiers for 39,000 different
locations in the United States, was time consuming, distracting and could be
detrimental to maritime safety. TSAC was asked to make recommendations
for improving the efficiency and clarity of AIS reporting.
For more information, please click here. While the call is open to the
public, the Coast Guard is asking interested participants to RSVP so the
agency can ensure that it has a conference bridge large enough to
accommodate all interested stakeholders. To RSVP, please contact Mr. Ken
Doyle, TSAC Alternate Designated Federal Officer, at
[email protected].
4
multiple industry-agency partnerships
have been effective in reducing regional
emissions issues. A Houston Ship
Channel monitoring study in Texas in
2007, undertaken in conjunction with
the Texas Commission on
Environmental Quality and the Coast
Guard, found that less than 10 percent
of emissions triggers on the Channel
were possibly attributable to tank
barges. In 2009, the Carville Air
Monitoring Study in Louisiana, done in
conjunction with the Louisiana
Department of Environmental Quality,
found that less than 2 percent of
emissions triggers could be attributed to
tank barges. Most recently, in 2011, a
joint effort between the Texas Waterway
Operators Association, the East Harris
County Air Partnership and the
Environmental Defense Fund found that
only one tank barge out of 250
monitored underway was observed to
have inadvertent emissions.
Environmental representatives on the
panel agreed that there was strong
anecdotal evidence that the BMPs
have been successful in reducing
emissions from barges and praised the
industry for its proactive work on this
issue. Panelists agreed that moving
forward, public outreach will be key in
promoting the successful industryagency work on barge emissions, even
as they acknowledged that states have
recently begun to look to other
possible emissions sources.
The TRB Annual Meeting is attended
by nearly 12,000 transportation
professionals every year, including
researchers and policy makers. AWO
is committed to using this and other
forums to promote the environmental
stewardship of the tugboat, towboat
and barge industry. For more
information, please contact Brian
Vahey at (703) 841-9300, extension
251, or [email protected].
February 11, 2014
REGIONAL REPORTS
Atlantic Region
Atlantic Region Annual Meeting
Takes Place in Baltimore
AWO Atlantic Region members
gathered in Baltimore on January 29-30
for their Annual Meeting. In addition
to the Annual Meeting, the Atlantic
Regional Quality Steering Committee
of the Coast Guard-AWO Safety
Partnership held an industry-only
meeting to discuss its Quality Action
Team on port coordination. (Coast
Guard members of the RQSC had to
cancel plans to attend the meeting due
to weather-related travel problems.)
The Annual Meeting began with a
discussion session on January 29 led
by Atlantic Region Chairman Stephen
Dann, Dann Ocean Towing, Inc. Mr.
Dann gave brief remarks and
introduced the day’s speakers including
Tom Allegretti, AWO President &
CEO, who discussed AWO’s 2014
focus and game plan, including an
update on the implementation of the
recommendations of the Task Force on
Future Missions and Capacity.
Members also heard updates from John
Harms, Manager – Atlantic Region, on
the organization’s progress toward
achieving its Board-approved PAC
goals and from Ann McCulloch,
Director – Public Affairs &
Communications, on AWO’s strategic
plan to grow its public affairs program.
Brian Vahey, Government Affairs
Manager, then updated members on
international requirements and how
they are impacting AWO’s coastal
operators. Jennifer Carpenter,
Executive Vice President, presented the
proposed 2014 national priorities for
member discussion. A motion was
made to accept the national priorities
and, after review at the Pacific Region
annual meetings, the proposed national
priorities will be presented to the AWO
Board of Directors for approval at its
April meeting.
February 11, 2014
Following the business session, AWO
members and Coast Guard officials
gathered for a reception sponsored by
Water Quality Insurance Syndicate.
The annual meeting continued on
January 30 with a breakfast sponsored
by Dann Marine LC followed by a
business session sponsored by Lyon
Shipyard, Inc. and led by Mr. Dann. In
his chairman’s report, AWO Chairman
Buckley McAllister, McAllister
Towing, emphasized the importance of
ensuring that AWO continues to
provide high value to its members.
CAPT Kevin Kiefer, Commander, U.S.
Coast Guard Sector Baltimore,
summarized some of the initiatives
underway in his area of responsibility,
including the successful Towing Vessel
Bridging Program. Mr. Harms
presented the proposed 2014 priorities
for the Atlantic Region, which
included a new priority on ensuring
that standards for safe manning
documents are applied consistently and
expediently across all sectors in the
Atlantic Region. The priorities were
unanimously approved and can be read
by clicking here.
Emile Benard of Booz Allen Hamilton,
who has been supporting the Coast
Guard Atlantic Area as the Project
Manager for the Atlantic Coast Port
Access Route Study for the last three
years, discussed the status of ACPARS
and recent developments surrounding
several offshore wind energy projects
that could impact AWO members.
AWO’s Holly Riester, Director –
Safety and Environmental
Stewardship, updated members on the
2013 achievements and 2014 goals of
the safety and environmental program.
Members also approved the slate of
Atlantic Region directors presented by
the Atlantic
Region
nominating
committee, which
will be presented
for approval at the
Annual AWO Membership Meeting in
April. Croft Register, Express Marine,
Inc.; Jeff Parker, Kirby Offshore
Marine, LLC; Rick Iuliucci, The Vane
Brothers Company; and Hugh
McCrory, Norfolk Tug Company, were
nominated to the Board. Linda Marra,
Greater NY Marine Transportation,
LLC, was nominated as the alternate.
J.C. Dann, Dann Marine LC, and Ted
Tregurtha, Moran Towing Corporation,
were nominated to serve two-year
terms as Atlantic Region Chairman and
Vice Chairman, respectively.
Following the conclusion of the annual
meeting, the industry members of the
Atlantic RQSC held a meeting to
discuss the draft final report of the Port
Coordination QAT. Steve Kress,
McAllister Towing, Mr. Stephen Dann,
Mr. Parker, and Mr. Harms, who were
the industry members on the QAT,
discussed the QAT’s recommendations
to improve communication and
coordination between the Coast Guard
and the towing industry during severe
weather and security events. The
industry members of the RQSC voted
unanimously to approve the substance
of the draft final report. The report will
now go to the full RQSC for approval
before it is considered and endorsed by
the National QSC.
All meeting packets and presentations
are available here. For more
information about the Atlantic Region
annual meeting, please contact John
Harms at (703) 841-9300, extension
292, or [email protected].
5
REGIONAL REPORTS
Atlantic Region
AWO Submits Comments Urging Chicago to Change
Petcoke Rule; Illinois EPA Rulemaking Still Pending
On February 7, AWO submitted
comments to the City of Chicago
Department of Public Health on a
proposed rule regulating petroleum
coke (petcoke), coal, and other bulk
materials. In its comments, AWO
articulated that barge transportation is
the nation’s most environmentally
friendly mode of transportation and
reiterated the industry’s commitment to
environmental stewardship.
AWO’s comments described the
Chicago Area Waterways as highly
trafficked federal waterway regulated
by the federal government including
the U.S. Coast Guard and U.S.
Environmental Protection Agency. The
comments continued to illustrate the
negative impacts that could occur if the
city put operational requirements on
barges moving on federal waterways.
The comments also highlighted several
concerns, including the following:
•
•
•
Barges
are
Beautiful...
For American Jobs.
America’s tugboat, towboat
and barge industry:
Q Provides good paying, family-wage
jobs for Americans, jobs that cannot
be outsourced
Q
Offers excellent career opportunities
for hard-working Americans
Q
Fosters hundreds of thousands
of American jobs that depend
on waterways transportation,
and directly employs over 30,000
Americans on our vessels
Q
Contributes to America’s economic,
national and homeland security
because our vessels are Americanowned, American-built and
American-crewed
THE AMERICAN WATERWAYS OPERATORS
America’s Tugboat, Towboat & Barge Industry
“Our Compass Always Points to Safety”
•
Definitions in the proposed
regulation could be interpreted to
apply to a wide range of
commodities outside the
regulation’s stated purpose;
The stated objective of the rule
doesn’t match the actual risks as
petcoke has been found non-toxic
and non-hazardous in a study
conducted by the EPA;
The requirements for barges
loading and unloading in enclosed
spaces are impractical for
operations and could cause more
damage to other infrastructure; and,
Requiring tarps on hopper barges
would make transport cost
prohibitive and would cause
serious safety issues on vessels.
AWO urged the city to withdraw the
rule or amend it to prevent
unintentionally harming ancillary
business interests and remove the
requirements for tarps and for enclosed
loading/unloading areas.
As discussed in the January 28 AWO
Letter, the Illinois Environmental
Protection Agency has proposed a
similar rule that was rejected as an
emergency rulemaking, but will proceed
under the general rulemaking process. A
timeline to submit public comments on
that rule is not known at this time.
For more information, please contact
Lynn Muench at (314) 446-6474 or
[email protected] or Brian
Bennett at (703) 841-9300, extension
279, or [email protected].
www.americanwaterways.com
6
February 11, 2014